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Window Cleaning Risk Assessment

Window Cleaning Risk Assessment

  • • 100% Compliant with Australian WHS Acts & Regulations
  • • Fully Editable MS Word & PDF Formats Included
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  • • Includes 2 Years of Free Compliance Updates

Window Cleaning Risk Assessment

Product Overview

Identify and control organisational risks associated with Window Cleaning through a structured, management-level WHS Risk Management approach that focuses on governance, planning, systems, and equipment selection. This Risk Assessment supports compliance with the Work Health and Safety Act and Regulations while helping protect your business from operational disruption and liability exposure.

Risk Categories & Hazards Covered

This document assesses risks and outlines management controls for:

  • Governance & WHS Duties: Oversight of PCBU obligations, officer due diligence, allocation of safety responsibilities, and integration of window cleaning risks into corporate governance frameworks.
  • WHS Risk Management & Change Control: Assessment of hazard identification, risk assessment and control processes, including formal change management when new buildings, equipment, methods or chemicals are introduced.
  • Procurement & System Design: Management of equipment selection (poles, ladders, EWP, rope access gear), chemical products, and systems of work to ensure they are fit for purpose and compliant at the organisational level.
  • Competency, Licensing & Training: Verification of operator competency, high-risk work licences (where applicable), rope access qualifications, and ongoing training and refresher programs for window cleaning activities.
  • Safe Work Procedures & Work Instructions: Development, authorisation and review of documented procedures for internal and external window cleaning, including use of access equipment and cleaning agents.
  • Work at Height & Access Management: Controls for elevated work platforms, ladders, rope access, building maintenance units and fall protection systems, including anchor point management and access planning.
  • Equipment Inspection & Asset Management: Organisational systems for inspection, testing and maintenance of ladders, harnesses, fall arrest systems, EWP, BMUs, poles and associated plant and equipment.
  • Contractor & Labour-Hire Management: Prequalification, selection, induction and performance monitoring of contractors, subcontractors and labour-hire workers engaged in window cleaning operations.
  • Planning, Scheduling & Environmental Conditions: Assessment of job planning, traffic and pedestrian interface, weather and environmental conditions (wind, rain, glare, heat) and their impact on safe window cleaning operations.
  • Public & Third-Party Interface: Management of risks to building occupants, visitors and the public, including exclusion zones, signage, barricading and communication with facility management.
  • Manual Handling, Ergonomics & Health: Controls for repetitive movements, awkward postures, handling of poles, buckets and equipment, and exposure to chemicals and occupational health risks.
  • Emergency Preparedness & Incident Management: Planning for rescue from height, equipment failure, medical emergencies, chemical exposure and incident reporting, investigation and corrective actions.
  • Consultation, Communication & Engagement: Systems for worker consultation, toolbox talks, communication of hazards and controls, and feedback mechanisms for continuous improvement.
  • Compliance, Monitoring & Continuous Improvement: Internal audits, inspections, KPI monitoring, corrective action tracking and review of the window cleaning safety management system.

Who is this for?

This Risk Assessment is designed for Business Owners, Property and Facilities Managers, WHS Managers and Safety Officers responsible for planning, overseeing and controlling Window Cleaning operations across their organisation or sites.

Hazards & Risks Covered

Hazard Risk Description
1. Governance, WHS Duties and PCBU Oversight
  • • Lack of clear allocation of WHS duties between PCBU, officers, managers, supervisors and workers for window cleaning operations at all heights
  • • Inadequate due diligence by officers to ensure resources and processes are in place to manage high‑risk work such as high‑rise and skylight window cleaning
  • • Absence of a documented WHS management system covering specialised tasks like waterfed pole systems, lowering and raising sashes, and sash cord adjustments
  • • Poor integration of window cleaning activities into the broader organisational WHS plan, risk register and consultation arrangements
  • • Failure to verify that subcontractors and labour‑hire providers comply with WHS Act 2011 and relevant Regulations and Codes of Practice
  • • Inadequate review of incidents, near misses and industry alerts relating to work at height and fragile surfaces (e.g. skylights, old sashes)
2. WHS Risk Management Framework and Change Management
  • • No consistent methodology for identifying and assessing risks associated with high‑rise, at‑height and skylight window cleaning work
  • • Failure to consider hierarchy of control when selecting control measures for extension pole use, waterfed pole systems and access to external façades
  • • Poor change management when building design, glazing types, access methods or equipment are altered (e.g. introduction of new waterfed pole technology)
  • • Inadequate pre‑commencement risk assessments for non‑routine work such as sash cord adjustments, skylight cleaning or unusual façade configurations
  • • Insufficient consultation with workers and HSRs when developing or reviewing risk assessments for window cleaning tasks
  • • Failure to assess cumulative risks from weather, nearby traffic, public interface, and other contractors working above or below
3. Procurement and Design of Equipment and Systems of Work
  • • Selection of inappropriate or low‑quality window cleaning equipment (e.g. extension poles, waterfed poles, anchors) not compliant with Australian Standards
  • • Failure to consider ergonomics, reach, load ratings and compatibility of equipment with high‑rise façades, skylights and old sash windows
  • • Procurement driven solely by cost rather than WHS performance and lifecycle maintenance requirements
  • • Lack of standardisation of equipment leading to confusion, misuse and difficult maintenance control
  • • Inadequate design review of new buildings or refurbishments to ensure safe external window cleaning access (e.g. anchors, davits, BMUs, platforms, safe access paths)
  • • Use of non‑certified or unsuitable fixing points for harnesses or rope access when cleaning high‑rise external windows
  • • No system for verifying that supplied sashes, sash cords and skylight assemblies are safe and suited to repeated cleaning operations
4. Competency, Licensing and Training Systems
  • • Inadequate competency of workers and supervisors in work at height principles, including use of fall arrest systems, anchor points and rope access
  • • Lack of specific training in safe use of extension poles, waterfed pole systems and techniques for preventing over‑reaching and musculoskeletal strain
  • • Insufficient training in recognising structural defects in sashes, sash cords, window frames, skylights and windowsills that may fail under load
  • • Supervisors not competent to verify correct setup and use of high‑rise access systems, including harnesses, anchors and rope systems
  • • No formal induction covering building‑specific access arrangements, restricted areas, emergency procedures and exclusion zones around public thoroughfares
  • • Failure to provide refresher training, competency reassessment and verification of licences (e.g. for rope access or EWP use where applicable)
5. Safe Work Procedures and Work Instructions
  • • Absence of clear, documented safe work procedures for high‑rise and at‑height window cleaning, including skylights and external façades
  • • Inconsistent instructions for lowering and raising sashes and adjusting sash cords, leading to potential uncontrolled movement or failure of window units
  • • No documented limitations on the use of extension poles and waterfed pole systems near electrical hazards, in high winds or on unstable ground
  • • Procedures not tailored to different building designs, access systems, façade materials and window types (e.g. heritage sashes vs modern glazing)
  • • Safe work procedures not easily accessible to workers in the field or not integrated into daily planning and pre‑start processes
  • • Over‑reliance on informal verbal instructions and practices passed between workers without formal review or approval
6. Work at Height and Access Management Systems
  • • Inadequate systems of work to prevent falls during window cleaning at height, including external façades, balconies, roofs and skylights
  • • Reliance on administrative controls rather than engineered solutions such as guardrails, walkways, anchor points or building maintenance units
  • • Uncontrolled use of ladders and makeshift platforms for reaching high windows or windowsills
  • • Poor planning for rope access, EWP use or other specialised access methods, including inadequate rescues plans
  • • Lack of documented criteria for determining when work should be done from inside the building versus from outside using harness or rope systems
  • • Insufficient control of simultaneous operations (e.g. other trades working above or below window cleaners) creating falling object and interference risks
7. Equipment Inspection, Maintenance and Asset Management
  • • Failure of critical equipment such as harnesses, lanyards, anchors, ropes, extension poles, waterfed poles and fittings due to inadequate inspection and maintenance
  • • Lack of tracking of inspection dates, service history and retire‑from‑service criteria for fall arrest and rope access equipment
  • • Use of damaged or worn components in sash mechanisms and skylight opening systems during cleaning operations
  • • Poor maintenance of pumps, filtration units and hoses for waterfed pole systems leading to sudden pressure changes, leaks or erratic movements
  • • Unreported damage to windowsills, frames or glazing caused by prior work, increasing risk of collapse or breakage during subsequent cleaning
  • • No systematic check on third‑party supplied equipment from subcontractors or building owners (e.g. BMUs, anchors, EWPs)
8. Contractor, Subcontractor and Labour‑Hire Management
  • • Subcontracted window cleaning crews operating under different or inadequate WHS standards compared with the principal PCBU
  • • Lack of clarity over who controls the workplace and who is responsible for implementing specific control measures for high‑rise and external window cleaning
  • • Insufficient review of subcontractors’ work at height systems, competency, insurance and incident history
  • • Inadequate induction and onboarding processes for labour‑hire workers performing window cleaning at height or skylight tasks
  • • Poor communication of building‑specific hazards (e.g. fragile roofs, old sashes, restricted anchor points) to external providers
  • • No system for monitoring subcontractor performance and rectifying non‑conformances identified during audits or site inspections
9. Planning, Scheduling and Environmental Conditions Management
  • • Inadequate planning of high‑rise and external window cleaning around adverse weather conditions (wind, rain, lightning, extreme heat or cold)
  • • Rushed work due to unrealistic timeframes, leading to shortcuts in setup, inspection and safe access arrangements
  • • Failure to coordinate with building occupants and management regarding access to internal areas for lowering/raising sashes and skylight operations
  • • No systematic consideration of public interface, traffic management and pedestrian exposure beneath work areas
  • • Poor planning for out‑of‑hours work, including lone work scenarios and reduced access to emergency assistance
  • • Insufficient consideration of glare, reflection and visibility issues affecting safe use of extension and waterfed poles, particularly at height
10. Public, Building Occupant and Third‑Party Interface
  • • Members of the public or building occupants struck by falling tools, cleaning equipment or glass during external or high‑rise window cleaning
  • • Uncontrolled access of tenants, visitors or other workers into areas beneath overhead window cleaning operations
  • • Cleaners inadvertently entering secure or sensitive areas without appropriate authorisation or briefing
  • • Inadequate communication with occupants about sash adjustments, skylight operations or temporary loss of use of windows and balconies
  • • Public slips, trips or contact with water from waterfed pole runoff on footpaths and entryways
  • • Reputational damage and regulatory scrutiny following injuries to third parties arising from poorly controlled window cleaning work
11. Manual Handling, Ergonomics and Occupational Health
  • • Musculoskeletal strain from repetitive movements, awkward postures and sustained overhead work with extension and waterfed poles
  • • Manual handling injuries from carrying, lifting and transporting equipment such as poles, hoses, ladders and buckets between levels and across sites
  • • Cumulative strain from operating on windowsills, leaning out of openings or managing heavy or stiff sashes and skylights
  • • Long‑term health effects from exposure to cleaning chemicals, contaminated water or biological agents (e.g. mould around skylights and frames)
  • • Insufficient systems for early reporting of discomfort, minor injuries and signs of overuse among window cleaners
  • • Inadequate consideration of fatigue management, particularly during long shifts, hot conditions or repetitive routes
12. Emergency Preparedness, Rescue and Incident Management
  • • Lack of effective rescue plans for workers suspended in harnesses or ropes during high‑rise and at‑height window cleaning
  • • Delayed emergency response due to unclear access routes, poor communication systems or lack of coordination with building management and emergency services
  • • Inadequate first aid arrangements for falls, cuts from broken glass, chemical exposure or heat‑related illness
  • • Workers unaware of procedures for dealing with failure of anchor points, roof access hatches, or uncontrolled movement of sashes and skylights
  • • Insufficient incident reporting and investigation, leading to recurrence of similar high‑risk events
  • • No drills or testing of emergency plans for high‑rise rescues or skylight fall‑through scenarios
13. Consultation, Communication and Worker Engagement
  • • Workers not consulted about practical risks and control effectiveness for window cleaning at different sites and building types
  • • Information about building‑specific hazards, such as fragile skylights or deteriorated sash cords, not effectively communicated to all relevant workers and subcontractors
  • • Language barriers, literacy issues or cultural differences leading to misunderstanding of procedures and safety expectations
  • • Lack of structured mechanisms for workers to raise WHS concerns related to high‑rise, skylight and external window cleaning work
  • • Poor feedback loops from incidents and audits to front‑line workers, resulting in repeated errors
  • • Inconsistent communication between organisational management, site supervisors and client building managers regarding WHS responsibilities and controls
14. Compliance, Monitoring and Continuous Improvement
  • • Non‑compliance with WHS legislation, Codes of Practice and Australian Standards relating to work at height and window cleaning
  • • Lack of systematic monitoring of WHS performance indicators specific to window cleaning operations
  • • Audit findings and corrective actions not implemented or closed out in a timely manner
  • • Complacency arising from frequent low‑level incidents or long periods without serious harm, leading to erosion of controls
  • • Failure to keep up with industry best practice and technological developments for safer window cleaning methods (e.g. improved waterfed pole systems, automated façade cleaning)
  • • Inadequate records management for training, inspections, permits and incident reports

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Legislation & References

This document was researched and developed to align with:

  • Work Health and Safety Act 2011
  • Work Health and Safety Regulations 2017
  • Code of Practice: How to Manage Work Health and Safety Risks: Guidance on risk management processes for window cleaning activities.
  • Code of Practice: Managing the Risk of Falls at Workplaces: Requirements and controls for work at height, including window cleaning on elevated surfaces.
  • Code of Practice: Managing the Work Environment and Facilities: Provisions for safe access, amenities and environmental conditions during cleaning operations.
  • Code of Practice: Managing Risks of Plant in the Workplace: Controls for EWPs, BMUs, ladders and other plant used for window cleaning.
  • AS/NZS ISO 31000:2018: Risk management — Guidelines
  • AS/NZS 1891 (Series): Industrial fall-arrest systems and devices used for harness-based window cleaning tasks.
  • AS/NZS 4576: Guidelines for scaffolding where temporary platforms are used for access to windows.
  • AS 2550 (Series): Cranes, hoists and winches – Safe use, including relevant guidance for building maintenance units and suspended access equipment.
  • AS/NZS 4801 / ISO 45001: Occupational health and safety management systems – Principles applied to the organisational control of window cleaning activities.
Standard Risk Assessment Features (Click to Expand)
  • Comprehensive hazard identification for all activities
  • Risk rating matrix with likelihood and consequence analysis
  • Existing control measures evaluation
  • Residual risk assessment after controls
  • Hierarchy of controls recommendations
  • Action priority rankings
  • Review and monitoring requirements
  • Consultation and communication records
  • Legal compliance references
  • Sign-off and approval sections

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